Respondent operated a cold storage warehouse and distribution facility located in RI (the “Facility”). The Facility is located immediately adjacent to a Bay, approximately one-third of a mile from several marinas, just under 1 mile from a few homes, and less than 1.5 miles from an elementary school, a residential neighborhood, and a small airport. At all times relevant to the violations alleged herein, the Facility’s anm1onia refrigeration system (“System”) used approximately 8,700 pounds of anhydrous ammonia. Accordingly, Respondent “stored” and “handled” anhydrous ammonia, which is subject to the General Duty Clause.
EPA and the U.S. Department of Justice jointly determined that this matter, although it involves alleged violations that occurred more than one year before the initiation of this proceeding, is appropriate for administrative penalty assessment.
As discussed below, the CAFO resolves the following violations that Complainant alleges occurred in connection with Respondent’s storage and handling of anhydrous ammonia at its fish processing and cold storage facility in RI:
a. Failure to design and maintain a safe facility, taking such steps as are necessary to prevent such releases, in violation of Section 112(r)(1) of the CAA; and
b. Failure to minimize the consequences of a release should one occur, in violation of Section 112(r)(1) of the CAA.
The intent of Section 112(r)(1) of the CAA is for facility owners and operators to implement all feasible means to reduce the threat of death, serious injury, or substantial property damage to satisfy the requirements of the General Duty Clause.
EPA routinely consults codes, standards, and guidance issued by chemical manufacturers, trade associations, and fire prevention associations (collectively, “industry standards”) to understand the hazards posed by using various extremely hazardous substances. The industry standards also are evidence of the standard of care that industry itself has recognized to be appropriate for managing those hazards. These industry standards are consistently relied upon by industry safety and fire prevention experts and are sometimes incorporated into state building, fire, and mechanical codes.
GENERAL ALLEGATIONS
Due to the dangers associated with anhydrous ammonia, the ammonia refrigeration industry has developed industry standards to control the risks associated with the use of ammonia, specified in Appendix A. These standards are consistently relied upon by refrigeration experts and are sometimes incorporated by reference into state building and mechanical codes.
- On November 22, 2020, approximately 16 pounds of anhydrous ammonia were released from a cracked nipple on a compressor at the Facility.
- On January 6, 2021, less than one pound of anhydrous ammonia was released from a leaking seal on a compressor oil pump at the Facility.
- On June 29, 2021, approximately nine pounds of anhydrous ammonia were released from a leak on the Facility’s auto purger, resulting in an injury to an employee.
On July 8, 2021, two duly authorized EPA inspectors and an Eastern Research Group, Inc. (“ERG”) contract inspector (collectively, the “EPA Inspectors”) conducted an inspection at the Facility (the “Inspection”) alongside representatives of the Department of Homeland Security, OSHA, the local Fire Department, the Rhode Island Department of Enviromnental Management, and the Rhode Island State Fire Marshal’s Office. The purpose of EPA’s Inspection was to determine whether Respondent was complying with Section 112(r) of the CAA, EPCRA, and the Comprehensive Environmental Response, Compensation, and Liability Act’s (“CERCLA”) release notification procedures.
The inspectors toured the Facility’s perimeter, storage building, roof, ammonia machinery room (“AMR”), maintenance shop area, freezer and freezer dock area rooms, and forklift maintenance and auxiliary storage rooms. During the Inspection, EPA observed numerous potentially dangerous conditions relating to the anhydrous ammonia refrigeration system at the Facility; additional potentially dangerous conditions were identified based on a review of documents provided by Respondent.
The potentially dangerous conditions identified by EPA are listed in the chart attached to and made a part of this CAFO as Appendix A. Appendix A also explains how each of the conditions could lead to a release or inhibit the Facility’s ability to minimize the consequences of any release that might occur and includes examples of recognized industry standards of care that could feasibly reduce or eliminate the hazard.
VIOLATIONS
COUNT I- FAILURE TO DESIGN AND MAINTAIN A SAFE FACILITY
The recommended industry practice and standard of care for designing and maintaining a safe facility so as to prevent releases of extremely hazardous substances is to base design considerations upon applicable design codes, federal and state regulations, and industry guidelines to prevent releases or minimize their impacts as well as to develop and implement standard operating procedures, maintenance programs, personnel training programs, management of change practices, incident investigation procedures, self-audits, and preventative maintenance programs.
EPA’s Guidance for Implementation of the General Duty Clause: Clean Air Act Section 112(r)(J) (May 2000) (“EPA’s GDC Guidance”) explains broad categories of measures appropriate for preventing releases of extremely hazardous substances, and the International Institute of Ammonia Refrigeration and others have developed more specific standards and guidelines for preventing releases of ammonia, set out in Appendix A.
The instances in which EPA alleges that Respondent failed in its general duty to design and maintain the Facility in a safe manner, taking such steps as are necessary to prevent a release of an extremely hazardous substance, are listed under Conditions 1-5 of Appendix A, which is incorporated by reference into this CAPO. They include, for example, the failure to provide impact protection and adequate supports for piping and equipment, to address areas of breached insulation and corrosion, and to adequately label all ammonia piping.
Examples of industry standards associated with each instance in which Respondent failed in its general duty to design and maintain a safe facility (identified in Appendix A) demonstrate that the hazard is recognized by the ammonia refrigeration industry and that the industry has identified a feasible means by which Respondent could have eliminated or reduced the hazard. Further, Appendix A identifies, for each condition, how the failure to address the hazard could lead to or exacerbate a release of anhydrous ammonia and cause harm.
Accordingly, from at least September 30, 2018 through April 28, 2022, EPA alleges that Respondent failed to design and maintain a safe facility, taking such steps as were necessary to prevent a release of an extremely hazardous substance, in violation of the General Duty Clause, Section 112(r)(1) of the CAA, 42 U.S.C. § 7412(r)(1).
COUNT II- FAILURE TO MINIMIZE THE CONSEQUENCES OF ACCIDENTAL RELEASES THAT MIGHT OCCUR
Industry standards and guidelines for minimizing the consequence of an accidental release from ammonia refrigeration systems are found, among other places, in the industry standards referenced in Appendix A. They include emergency planning and preparedness measures, as well as design and maintenance measures to minimize the severity and duration of releases that do occur.
The instances in which EPA alleges that Respondent failed in its general duty to minimize the consequences of a release should one occur are listed under Conditions 4 and 6-12 of Appendix A, which is incorporated by reference into this CAFO. They include, for example, the failure to provide safely designed ventilation and pressure relief systems, adequate signage/labeling, and accessible eyewash/safety shower units inside and outside the machinery room.
Accordingly, from at least September 30, 2018 through May 26, 2022, EPA alleges that Respondent failed to minimize the consequences of an accidental release of an extremely hazardous substance should one occur, in violation of the General Duty Clause, Section 112(r)(1) of the CAA.
V. TERMS OF SETTLEMENT
Taking into account the relevant statutory penalty criteria, the applicable penalty policies, and the Respondent’s cooperation in agreeing to perform the non-penalty obligations in this CAFO, EPA has determined that it is fair and proper to assess a civil penalty of $122,622 for the violations alleged in this matter.
Appendix A – Recognized and Generally Accepted Good Engineering Practices
In collaboration with the American National Standards Institute, the International Institute of Ammonia Refrigeration (“IIAR”) has issued and updates, among others,
- Standard 2: Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems (“ANSIIIIAR 2”);
- Standard 4: Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems (“ANSI/HAR 4”),
- Standard 5: Start-up and Commissioning of Closed Circuit Ammonia Refrigeration Systems (“ANSI/IIAR 5”);
- Standard 6: Standard for Testing, Inspection, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems (“ANSI/IIAR 6”),
- Standard 7: Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating Systems (“ANSI/IIAR 7”), and
- Standard 9: Standard for Minimum System Safety Requirements for Existing Closed-Circuit Ammonia Refrigeration Systems (“ANSI/IIAR 9”), inter alia, along with other applicable standards and guidance. Bulletins and guidance include, without limitation,
- IIAR Bulletin No. 109, Guidelines for I1AR Minimum Safety Criteria for a Safe Ammonia Refrigeration System (1997, and in effect until 2019 when ANSI/IIAR 6 replaced it) (“IIAR Bull. 109”);
- IIAR Bulletin No. 110, Guidelines for Start-Up, Inspection, and Maintenance of Ammonia Mechanical Refrigerating Systems (1993, most recently updated in 2007, and in effect until 2019 when ANSI/IIAR 6 replaced it) (“IIAR Bull. 110”);
- IIAR Bulletin No. 114, Guidelines for Identification of Ammonia Refrigeration Piping and Components (1991, most recently updated in 2018) (“IIAR Bull. 114”);
- IIAR Bulletin No. 116, Guidelines for Avoiding Component Failure in Industrial Refrigeration Systems Caused by Abnormal Pressure or Shock (1992) (“IIAR Bull. 116”); and
- the Ammonia Refrigeration Management Program (2005, most recently updated in 2019) (“IIAR ARM Program”), which is intended to provide streamlined guidance to systems that have less than 10,000 pounds of ammonia.
Also in collaboration with the American National Standards Institute, the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (“ASHRAE”) has issued (and updates) “Standard 15: Safety Standard for Refrigeration Systems.”
These standards are consistently relied upon by refrigeration experts and are often incorporated into state building and mechanical codes. The chart cites to the standards of care that were in effect in 2021, when the inspection occurred.
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Alleged Hazards/Dangerous Condition |
GDC Violation |
How Condition Could Lead to or Exacerbate the Consequences of a Release, Causing Harm |
Examples of Industry Standards of Care, Showing that (1) Hazard is Recognized by Owner/Operator’s Industry, and (2) There are Way(s) to Eliminate or Reduce the Hazard |
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Condition 1 Peeling paint and surface corrosion were observed on the control pressure receiver (CPR), the high-pressure receiver, and piping associated with both vessels. |
Failure to design and maintain a safe facility taking such steps as are necessary to prevent releases. |
Corrosion can weaken piping and vessels to the point where it fails, causing a release. |
The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to regularly inspect pressure vessels and piping for degradation of the protective coating and corrosion clean do’WD. and repaint areas where corrosion has not yet materially reduced the wall thickness, and measure wall thickness and evaluate the potential for safe further use for areas where corrosion has materially reduced wall thickness. See, e.g., ANSI/IIAR 2-2014 § 13.4.2 (Refrigerant piping shall be isolated and supported to prevent damage from vibration, stress, corrosion, and physical impact.); ANSI/IIAR 9-2020 § 5.1 (All equipment and system components shall be inspected, tested, and maintained in accordance with ANSI/IIAR 6 (2019)); ANSI/IIAR 6-2019 §§ 10.1 (calling for annual visual inspection for pitting or surface damage and degradation of protective coating, i.e., paint, on uninsulated pressure vessels), 10.1.1 (Where pitting, surface damage, general corrosion, or a combination thereof; is visually observed on a metal surface of the pressure vessel, deficient areas shall be further evaluated.), 10.1.1.l (Where such corrosion is suspected to have materially reduced the vessel wall thickness beyond its permitted corrosion allowance, the remaining wall thickness shall be measured using appropriate techniques.), I 0.1.1.1.1 (Where such corrosion has not materially reduced the vessel wall thickness beyond its permitted corrosion allowance, the pressure vessel metal surface shall be cleaned and recoated to arrest further deterioration.), 10.1.1.1.2 (Where such corrosion has materially reduced the vessel wall thickness beyond its permitted corrosion allowance, the owner shall proceed in a timely manner with an analysis using specified criteria to determine suitability for continued operation); 11.1 (calling for annual visual inspection of piping for pitting and surface damage including degradation of protective coating, i.e., paint, on non-insulated piping and damage and/or moisture buildup in insulation on insulated piping,), 11.1.1 (where pitting, surface damage, general corrosion, or a combination thereof, is visually observed on a metal snrface of the piping, deficient areas shall be further evaluated), 11.1.1.1 (if corrosion has materially reduced the remaining pipe wall thickness, the piping remaining wall thickness shall be measured using appropriate techniques), 11.1.1.2 (if corrosion has not materially reduced the remaining pipe wall thickness, the piping metal surface shall be cleaned and recoated to arrest further deterioration), 11.1.1.3 (if corrosion has materially reduced the remaining pipe wall thickness, the piping shall be evaluated to determine suitability for continued operation). |
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Condition 2 EPA inspectors observed several instances of the insulation and/or jacketing on piping associated with the surge drams and other piping runs on the upper roof that was damaged or missing, and in some instances corroded piping was observed underneath. |
Failure to design and maintain a safe facility taking such steps as are necessary to prevent releases. |
Insulation vapor barrier protects pipes and vessels from moisture, which causes corrosion. Breached insulation can hold moisture against the external pipe surface, furthering corrosion. Corroded pipes and vessels can break or succumb to pressure, causing an ammonia release. |
The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to regularly inspect the condition of insulation and vapor barrier on piping, valves, and equipment, remove any sections of insulation or vapor barrier that are in poor condition, and replace the vapor barrier and insulation after any underlying corrosion has been addressed. See, e.g., ANSI/IIAR 2-2014 § 5.10.1 (piping and equipment surfaces not intended for heat exchange shall be insulated, treated, or otherwise protected to mitigate condensation and excessive frost buildup); ANSI/IIAR 9-2020 §§ 5. I (all equipment and system components shall be inspected, tested, and maintained in accordance with ANSI/IIAR 6-2019), 7.2.6.1 (Piping and equipment surfaces not intended for heat exchange shall be insulated, treated, or otherwise protected to mitigate condensation and excessive frost buildup where the surface temperature is below the dew point of the surrounding air during normal operation and in an area where condensation and frost could develop and become a hazard to occupants or cause damage to the structure, electrical equipment, or refrigeration system.); ANSI/IIAR 6-2019 §§ 11.1.2 (For insulated piping, where insulation is removed, partly or completely, for visual inspection or remaining wall thickness measurement(s), a protective coating shall be applied to the exposed metal surface and insulation shall be replaced in accordance with the manufacturer’s s installation instructions after arresting any identified exposed piping metal surface corrosion), Table 11.1 (piping), Inspection items (b) and (j) and Testing item (c) (calling for regular inspection of insulation and vapor barrier, and testing underneath areas of observed degraded insulation), and Table 11.1.6 (valves), Inspection items (b) and (f) and Testing items (a) and (b) (same). |
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Condition3 The ceiling-mounted evaporators in the Freezer #1 Dock Area did not have physical protection from forklift or pallet damage. |
Failure to design and maintain a safe facility by taking such steps as are necessary to prevent releases. |
Impacts to evaporators from forklifts or other operated equipment can result in an accidental release of ammonia. |
The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to install guarding or barricading to prevent ammonia piping and equipment from being subject to physical impact. See, e.g., ANSI/IIAR 2-2014, §§ 5.17.1 (Where ammonia-containing equipment is installed in a location subject to physical damage, guarding or barricading shall be provided.), 7.2.4 (Equipment shall be protected where a risk of physical damage exists. Where equipment containing ammonia is located in an area with heavy vehicular traffic during normal operations and a risk of impact exists, vehicle barriers or alternative protection shall be provided in accordance with the Fire Code.), 13.4.2 (Refrigerant piping shall be isolated and supported to prevent damage from vibration, stress, corrosion, and physical impact.); ANSI/IIAR 9-2020, § 7.2.12.1 (Where ammonia-containing equipment is installed in a location subject to physical damage, guarding or barricading, shall be provided.) |
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Condition 4 Significant portions of the ammonia piping associated with the CPR were not labeled to indicate contents, direction of flow, and physical state. |
Failure to design and maintain a safe facility taking such steps as are necessary to prevent releases. Failure to minimize the consequences of releases which do occur. |
The lack of proper pipe labeling makes it more difficult to properly maintain system, increases chance of accidental release of ammonia, and could frustrate efforts to respond quickly in the event of a release. |
The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to label all piping with the identity, physical state, and relative pressure of the contents, as well as direction of flow. See, e.g., ANSI/IIAR 2-2014 §§ 5.14.5 (piping shall be labeled with the identity, physical state, and relative pressure of the contents, along with the pipe service and direction of flow), 6.6.3 (piping shall be marked as required by Section 5.14.5); ANSI/IIAR 9-2020 § 7.2.9.4 (piping shall be labeled with the identity, physical state, and relative pressure of the contents, along with the pipe service and direction of flow). |
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Condition 5 The control pressure receiver was resting on supports that were not properly secured. |
Failure to design and maintain a safe facility taking such steps as are necessary to prevent releases. |
Adequate equipment supports can prevent detrimental vibration or movement that might make the equipment fail and release ammonia. |
The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to provide adequate supports to prevent excessive vibration or movement of equipment. See, e.g., ANSI/IIAR 2-2014 §§ 5.11.5 (Supports and foundations shall be designed to prevent excessive vibration or movement of piping, tubing, and equipment.), 6.2.4 (Machinery shall be mounted in a manner that prevents excessive vibration from being transmitted to the building structure or connected equipment.); ANSI/IIAR 9-2020 §§ 7.2.7.1 (Piping, tubing, and equipment shall be supported to prevent excessive vibration and movement.), 7.3.2.3 (Supports and foundations shall be adequate to prevent movement of the equipment.), 7.3.2.4 (Supports and foundations shall be adequate to prevent excessive vibration of the equipment.). |
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Condition 6 The paths of travel to eyewash/safety shower units inside and outside of the AMR were obstructed by equipment and other materials. |
Failure to minimize the consequences of releases which do occur. |
Makes it difficult for emergency responders and workers to safely respond to releases and wash off this corrosive, toxic chemical in the event of exposure. |
The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to provide at least one easily accessible eyewash/safety shower unit in each machinery room and one easily accessible eyewash/safety shower unit outside each machinery room. ANSI/IIAR2-2014, §§ 6.7.1 (requiring a minimum of two eyewash/safety shower units-one located inside the AMR, and one located outside the AMR); 6.7.2 (the path of travel within the machinery room to at least one eyewash/safety shower unit shall be unobstructed and shall not include intervening doors), 6.7.3 (Emergency eyewash/safety shower unit installations shall comply with ANSI/ISEA Z358.1.); ANSI/IIAR 9-2020, §§ 7.3.7.1 (requiring a minimum of two eyewash/safety shower units, one located inside the AMR, and one located outside the AMR), 7.3.7.2 (the path of travel within the machinery room to at least one eyewash/safety shower unit shall be unobstructed and shall not include intervening doors), 7.3.7.3 (Emergency eyewash/safety shower unit installations shall comply with ANSI/ISEA Z358.1.); ANSI/ISEA 358.1-2009 § 7.4.2 (Combination eyewash/shower units shall be in accessible locations that require no more than 10 seconds to reach. The combination unit shall be located on the same level as the hazard and the path of travel shall be free of obstructions that may inhibit its immediate use.). |
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Condition 7 The CPR isolation/king valve was not labeled and was not accessible from the ground or a permanent working platform. |
Failure to minimize the consequences of releases which do occur. |
Labeling the King valve allows responding personnel the ability to easily identify the valve associated with the storage of ammonia in the system. The use of this valve provides responders a means of isolating a large quantity of ammonia during a release situation. |
The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to ensure critical valves are well-labeled and easily accessible from the ground level. See, e.g., ANSI/IIAR 2-2014 §§ 5.14.3 (Valves required for emergency shutdown of the system shall be clearly and uniquely identified at the valve itself and in the system schematic drawings), 6.3.3.2 (Manually operated isolation valves identified as being part of the system emergency shutdown procedure shall be directly operable from the floor or chain operated from a permanent work surface.); ANSI/IIAR 9-2020 §§ 7.2.9.3, 7.3.3.3(1)-(2) (same). |
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In the event of a release, being able to access critical valves is necessary for emergency response. Platforms or chains used to operate valves that are out of reach from ground level are necessary and aid first responders. |
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Condition 8 The pressure relief valves (PRVs) for surge drums 3 and 4 and associated equipment outside the machinery room discharged below the adjoining roofline. |
Failure to minimize the consequences of releases which do occur. |
Improperly placed discharge reliefs can result in ammonia being sprayed on personnel working on the roof or catwalks during a release, further exacerbating the consequences of a release. |
The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to elevate the discharge termination from pressure relief devices to be at least 7.25 feet above the roof (and nearby adjacent roofs) to avoid spraying people with ammonia. See, e.g., ANSI/IIAR2-2014 § 15.5.1.3 (The discharge termination from pressure relief devices relieving to the atmosphere shall not be less than 7.25 feet above a roof that is occupied solely during service and inspection. Where a higher adjacent roof level is within 20 feet horizontal distance from the relief discharge, the discharge termination shall not be less than 7.25 feet above the height of the higher adjacent roof.); ANSI/IIAR 9-2020 § 7.4.2.2 (same). |
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Condition 9 The machinery room’s mechanically operated ventilation air intake louvers did not fail to the open position upon loss of power. |
Failure to minimize the consequences of releases which do occur. |
In the event of a release in the AMR, make-up air is required and needed in order to properly exhaust the room. If the mechanically operated louvers do not fail open in the event of a power loss, make-up air may be cut off and the exhaust process short-circuited. |
The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to ensure that motorized louvers, where utilized, fail to the open position upon loss of power. See, e.g., ANSI/HAR 2-2014 § 6.14.5.6 (Motorized louvers or dampers, where utilized, shall fail to the open position upon loss of power); ANSI/IIAR 9-2020 § 7.3.13.3(5) (Motorized louvers or dampers, where utilized, shall fail to the open position upon loss of power). |
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Condition 10 The visual ammonia alarm located outside the machinery room near the control pressure receiver was not labeled to indicate its meaning. |
Failure to minimize the consequences of releases which do occur. |
Ammonia alarms provide early warning that a release is taking place, enabling quick response, and protecting workers, emergency responders, and the public from a larger release. Properly identifying ammonia alarms allows employees and responders the ability to determine what chemical is being released and helps distinguish between an ammonia release and a fire. |
The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to provide well-labeled audio and visual alarms inside and immediately outside each entrance to the machinery room. See, e.g., ANSI/IIAR 2-2014 §§ 6.13.1.3 (requiring audio/visual alarm within AMR and additional audio/visual alarms located outside each AMR entrance), 6.15.2 (alarm signage shall be provided in accordance with Section 17.6), 17.6 (requiring ammonia leak detection alarms to be identified by signage adjacent to visual and audible alarm devices); NFPA 1-2012 § 53.2.3.1.2 (audible and visual alarms shall be located inside the machinery room and outside each entrance to the room); ANSI/IIAR 9-2020 §§ 7.2.9.1.2 (The meaning of each alarm shall be clearly marked by signage near the visual and audible alarms.), 7.3.12.6 (Ammonia leak detection alarms shall be identified by signage adjacent to visual and audible alarm devices.), 7.3.12.1.3 (Audible and visual alarms shall be provided inside the machinery room. Additional audible and visual alarms shall be located outside of each entrance to the machinery room.). |
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Condition 11 Emergency equipment associated with the ammonia refrigeration system was not adequately labeled. For example, the system’s emergency control box was not labeled and was housed in a padlocked box. Also, emergency stop and emergency ventilation switches outside the AMR were not clearly identifiable upon approach. |
Failure to minimize the consequences of releases which do occur. |
Failure to label all refrigeration system components could frustrate efforts to respond quickly in the event of a release. In the event of a release, emergency responders need to be able to quickly identify and access emergency control switches, as timely use of these switches can reduce the duration and severity of an accidental release. |
The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to clearly label all refrigeration machinery, including emergency stop and emergency ventilation buttons. See, e.g., ANSI/IIAR 2-2014 §§ 5.14.2 (Refrigeration machinery shall be provided with labels), 6.12.1 (A clearly identified emergency shut-off switch with a tamper-resistant cover shall be located outside and adjacent to the designated principal machinery room door. The switch shall provide off-only control of refrigerant compressors, refrigerant pumps, and normally closed automatic refrigerant valves located in the machinery room. The function of the switch shall be clearly marked by signage near the controls.), 6.12.2 (A clearly identified control switch for emergency ventilation with a tamper-resistant cover shall be located outside the machinery room and adjacent to the designated principal machinery room door. The switch shall provide “ON/AUTO” override capability for emergency ventilation. The function of the switch shall be clearly marked by signage near the controls.); ANSI/IIAR 9-2020 §§ 7.2.9.2, 7.3.11.1, 7.3.11.2 (same). |